Cynthia, Thank you for the excellent suggestions. I would like to clear up a few issues though.
First is that a message of this type should be posted on the HCCO listserves instead of here. I don't think it is fair that HCCO discussions take place on WEDI listserves when the subject is mainly concerned with our processes. I would ask everyone that future messages focusing on HCCO not be posted here. Here is a response to your suggestions. Second, the mediation process for which you refer is a service to our membership as a way to resolve issues among members not intended to interfere with established mechanisms already in place. It is not really meant as a "whistle blower" process instead it is a way for organizations to discuss solutions before they become major problems and as a sponsor organization, it is a required element that would be part of our role. Transactions, Privacy and Security will have different protocols. For instance, Transactions will follow the ANSI Conformance Certification Program, Privacy will be decided shortly and Security must certainly follow an already accepted industry standard because Security requires certification. Mediation and arbitration are integral parts of the programs and the responsibility of the sponsoring organization. It is a mandatory element of any program that sponsors and accredits third party certifiers (which answers the age old question of who certified the certifier) and watches over them to ensure the quality of their programs and must get involved in case of disputes, that is the reference here of mediation as well as upcoming concerns with interoperability of multiple infrastructures. This is exactly how ISO, ANSI, UCC, etc all function in every other industry, these programs are not involved in HIPAA so we thought we would invite them in! It all comes down to the notion that healthcare is undergoing drastic changes in all practice areas and it is extremely pragmatic to not re-create the wheel but instead use industry proven solutions and methodologies to ensure conformance and especially business continuity of all the organizations involved in implementing HIPAA. SNIP is named in the legislation today but I thought it was meant as education. Honestly I never envisioned WEDI taking on the role as a sponsoring and accrediting agency, am I wrong? I thought they just issue recommendations? Can someone fill in the gaps for me here? As far as HCCO members serving on WEDI workgroups, that happens already. Actually most of the HCCO membership was part of WEDI, SHARP, MAHI, etc., well before we began and they continue to serve multiple roles as well. I think it is a great testament to the volunteerism of so many thoughtful and dedicated people we have in this industry, without it HIPAA implementation would be a much greater challenge if not impossible. Regards, Mark A Lott President/CEO HIPAA Testing, Inc. www.hipaatesting.com Executive Co-Chair HCCO - Transactions Group HIPAA Conformance Certification Organization www.hcco.us CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message -----Original Message----- From: Cynthia Korman [mailto:[EMAIL PROTECTED]] Sent: Friday, December 06, 2002 11:33 PM To: WEDI SNIP Testing Subworkgroup List Cc: Mark Lott Subject: Issue Mediation Hi Julie - re: education and mediation services that HCCO might offer, I hear you re: the appropriateness/importance of providing such a service. For any covered entity, rat-ing a trading partner out to CMS is an extreme measure to take, especially if all a covered entity wants to do is avoid being pulled in multiple directions by multiple trading partners as details of hipaa transaction conformance are ironed out. I firmly believe that this mediation process must meet the following standards: 1) It must integrate the HIPAA-mandated DSMO Change Request system http://www.hipaa-dsmo.org/crs/, and respect the change request dispositions made through that system since those decisions carry the force of law 2) It must provide feedback to the DSMOs (X12/HL7/NCPDP) 3) Its recommendations must be made open to the public (easily done through submission of DSMO Change Requests) If it doesn't meet these standards, how can the mediation process avoid creating shadow standards? Regarding your comment that HCCO will act as a completely neutral third party whose goal is the achieve compliance with the standard and maintain the cost savings/reduction originally planned in the legislation through the implementation of a single transaction standard for all covered entities - How does that differ from SNIP's mandate? If HCCO and SNIP tackle this independently, for each issue one of two things will happen 1) Great minds will think alike and a single resolution will be independently developed. 2) Intelligent people will differ, and when they come together through the DSMO process to debate their differences, the more rational argument will win. (as long as enough folks are willing to give their time to participate on the mediation committees!) Because the HIPAA legislation gives issue resolution authority to SNIP and the DSMOs, I think the HCCO folks who would be willing to take on mediation responsibility would be best advised to work instead through SNIP, since in the end SNIP will have the force of law. What's stopping HCCO'ers from chairing SNIP subcommittees? I know the SNIP Business Issues committee, which considers and resolves some of the DSMO CRS-captured issues, had committee chair positions open not too long ago - I don't know whether or not they've been filled... Best wishes! Cynthia Korman [EMAIL PROTECTED] ----- Original Message ----- From: "Julie Thompson" <[EMAIL PROTECTED]> To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]> Sent: Thursday, December 05, 2002 2:06 PM Subject: RE: HCCO Value Proposition > Correct other email dialogue offer the the FAQ in which CMS stated: > > CMS FAQ: How would someone file a complaint against a covered entity? > CMS will develop a web-based complaint management process, and will provide > information on this process as part of our HIPAA outreach activities. > > As a part of HCCO due diligence to serve its members, we will offer > education and mediation services which go beyond Medicaid and Medicare > requirements. > > PLEASE, PLEASE DO NOT INTERPRET THIS AS THE HIPAA POLICE! > > This is purely, clearly intended to be a front line anonymous arbitration > effort for our members. Many HCOs are unwilling to get directly involved in > trading partner issues. The relationships are too important! > > HCCO will act as a completely nuetral third party whose goal is the achieve > compliance with the standard and maintain the cost savings/reduction > originally planned in the legislation through the implementation of a single > transaction standard for all covered entities. > > All is favor, Say "I"! > > THANKS! > > Julie A. Thompson > > > > > > > From: "Rachel Foerster" <[EMAIL PROTECTED]> > Reply-To: "WEDI SNIP Testing Subworkgroup List" > <[EMAIL PROTECTED]> > To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]> > Subject: RE: HCCO Value Propistion > Date: Thu, 5 Dec 2002 11:07:27 -0600 > > I believe such an organization already exists - WEDi SNIP. Post 10/16/03 > complaints regarding non-compliance should be directed to the CMS > enforcement arm headed up by Jared Adair. > > Rachel Foerster > > -----Original Message----- > From: Julie Thompson [mailto:[EMAIL PROTECTED]] > Sent: Wednesday, December 04, 2002 3:50 PM > To: WEDI SNIP Testing Subworkgroup List > Subject: HCCO Value Propistion > > > I am working on several client implementations. There major concern is lack > of compliance (or none at all) from their trading partners. > > They do not want to cause a problem with their payors. > > What if there was an organization who they could report their concerns to, > and this organization would act as a first level of education and/or > mediation???"? > > Julie > > _________________________________________________________________ > STOP MORE SPAM with the new MSN 8 and get 2 months FREE* > http://join.msn.com/?page=features/junkmail > > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The > discussions on this listserv therefore represent the views of the individual > participants, and do not necessarily represent the views of the WEDI Board > of Directors nor WEDI SNIP. If you wish to receive an official opinion, post > your question to the WEDI SNIP Issues Database at > http://snip.wedi.org/tracking/. These listservs should not be used for > commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-testing as: [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at > http://subscribe.wedi.org or send a blank email to > [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as > the address subscribed to the list, please use the Subscribe/Unsubscribe > form at http://subscribe.wedi.org > > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The > discussions on this listserv therefore represent the views of the individual > participants, and do not necessarily represent the views of the WEDI Board > of Directors nor WEDI SNIP. If you wish to receive an official opinion, post > your question to the WEDI SNIP Issues Database at > http://snip.wedi.org/tracking/. These listservs should not be used for > commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-testing as: > [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at > http://subscribe.wedi.org or send a blank email to > [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as > the address subscribed to the list, please use the Subscribe/Unsubscribe > form at http://subscribe.wedi.org > > > _________________________________________________________________ > MSN 8 helps eliminate e-mail viruses. Get 2 months FREE*. > http://join.msn.com/?page=features/virus > > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-testing as: [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-testing as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-testing as: [email protected] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
